Luxury Camping Inc. and its wholly owned subsidiary, Ithaca by Firelight, LLC (IBF) understands the importance of your privacy and respect that you want to safeguard the use to which your personal information is put. Consequently, we make it a high priority to ensure that your personal information (including credit card details) remains secure and confidential and is used only for the intended purpose. In this privacy policy we explain how we collect data about you and the nature of that data, how we use that data, who that data may be sent to and how you can amend data you have submitted to us.

Our privacy policy applies to your personal data supplied or collected from our website (www.FirelightCamps.com or any other web page or website owned by Luxury Camping Inc.) and to personal data supplied or collected over the telephone, by e-mail, by fax or by letter.

We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices. We wish to help you make informed decisions, so please take a moment to read the sections below. We are committed to respecting your privacy and adhering to the principles of applicable data protection and privacy laws throughout the world.

UPDATES TO THE PRIVACY STATEMENT

IBF may amend this Privacy Statement from time to time in order to meet changes in the regulatory environment, business needs, or to satisfy the needs of our guests, properties, strategic marketing partners, and service providers. Updated versions will be posted to our web site and date stamped so that you are always aware of when the Privacy Statement was last updated.

TYPES OF INFORMATION WE COLLECT

We request information about our guests and visitors to our websites so that we can provide an experience that is responsive to our guests’ and visitors’ needs. Information may be collected as part of: (i) fulfilling reservation or information requests, (ii) purchasing products or services, (iii) registering for program membership, (iv) submitting a job application, (v) responding to communications from us (e.g., surveys, promotional offers, or reservation confirmations), (vi) accommodating your personal preferences, (vii) fulfilling requests for services or recommendations we provide you, (viii) working with third party sources, including collecting information available from social networking and other web sites, to better assist us with understanding your interests and to serve you better, (ix) your use of our apps on your electronic devices, (x) updating your contact information including your address (through such services as the National Change of Address Service in the United States), or (xi) facilitating the transmission of forward to a friend email at your request. The types of personally identifiable information (sometimes referred to as “PII”) that we collect may include your name, home, work and e-mail addresses, telephone, mobile telephone, and fax numbers, credit card information, date of birth, gender, and lifestyle information such as room preferences, leisure activities, names and ages of children, and other information necessary to fulfill special requests (e.g., health conditions that require special room accommodations).

We may also collect non-personally identifiable information about you, such as your use of our websites, communication preferences, travel habits, aggregated data relative to your stays, and responses to promotional offers and surveys. Please note, to better safeguard your information, please do not include any credit card information in your electronic communication unless it is specifically required by us as part of the reservation or transaction fulfillment process on our branded reservation web sites, or our customer contact centers.

HOW WE USE INFORMATION WE COLLECT

If you do provide us with Personal Data, we use it in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:

You may opt out of marketing emails and surveys at any time by clicking on the link included in such communications, or by contacting us directly at info@FirelightCamps.com to opt out of direct marketing, telemarketing, emails or surveys. You will always be offered the choice not to submit your PII or to decide what communications you want to receive from us. However, doing so may cause certain transactions to become affected. For example, not providing a name will prevent the processing of reservations.

OUR LEGAL BASIS FOR COLLECTING PERSONAL DATA

Whenever we collect Personal Data from you, we may do so on the following legal bases:

1. Your consent to such collection and use;

2. Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Products;

3. Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Data is necessary for:

- Product development and enhancement, where the processing enables IBF to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of our users, and to better understand how people interact with our Sites;

- Communications and marketing, including processing data for direct marketing purposes, and subject to your opt-in for these purposes, and to determine the effectiveness of our promotional campaigns and advertising;

- Fraud detection and prevention;

- Enhancement of our cybersecurity, including improving the security of our network and information systems; and

- General business operations and diligence;

PROCESSING AND DISCLOSURE

When processing your information, it may be necessary to transfer your PII to our affiliates and/or third party service providers located in the United States and throughout the world for the purposes outlined within this Privacy Statement. Unless otherwise precluded or governed by legal requirements and/or process, IBF subsidiaries, affiliates and property owners that may receive your information are required to abide by substantially similar privacy requirements relating to your PII.

INFORMATION WE SHARE

We do not share personal data with companies, organizations and individuals outside of the Organization unless one of the following circumstances applies:

· With your consent. We will share personal data with companies, organizations or individuals outside of IBF when we have your consent to do so.

· Owners and Franchisees. We may disclose Personal Data and Other Data to Owners and Franchisees of IBF branded properties for the purposes described in this Privacy Notice, such as providing and personalizing the Services and facilitating possibly future loyalty programs.

· Authorized Licensees. We disclose Personal Data and Other Data to our Authorized Licensees for the purposes described in this Privacy Statement, such as providing and personalizing the Services and fulfilling your requests. For example, this sharing enables you to purchase IBF branded goods and services.

· Strategic Business Partners. We disclose Personal Data and Other Data with select Strategic Business Partners who provide goods, services and offers that enhance your experience at our properties or that we believe will be of interest to you. By sharing data with these Strategic Business Partners, we are able to make personalized services and unique travel experiences available to you. For example, this sharing enables spa, restaurant, health club, concierge and other outlets at our properties to provide you with services.

· For external processing. We provide personal data to our affiliates or other trusted businesses or partners to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. These third parties include payment processors, such as financial institutions and their vendors and contractors that process transactions, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing and other services. It is our policy to only share Personal Data with contractors, service providers and other third parties who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. Under certain circumstances, you may avoid having us share your information with our business partners and vendors by not granting us permission to share your information. Not granting us permission to share your information with our business partners or vendors may limit your access to their services through the Sites. We do not share personal data with third parties for their own marketing purposes.

· For Legal Reasons. We will share Personal Data with companies, organizations or individuals outside of IBF if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

- protect against harm to the rights, property or safety of IBF, our Users or the public as required or permitted by law.

We attempt to notify Users about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

· Business Transfers . If we establish a new related entity, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, Personal Data about our users is often a transferred business asset. In the event that IBF itself or substantially all of our assets are acquired, Personal Data about our users may be one of the transferred assets.

· Aggregate Site Use Information. We may share aggregate and anonymized/pseudonymized Personal Data to third parties in order to promote or describe use of the Sites, for research, marketing, advertising, or similar purposes.

OTHER USES AND DISCLOSURES

We will not sell, license, transmit or disclose this information outside of IBF unless except:

1. If you expressly authorize us to do so

2. If it is necessary to allow our trusted service providers, affiliates, vendors, or agents to provide services for us

3. In order to provide our responses, products, or services to you

4. It is disclosed to entities that perform marketing services on our behalf or to other entities with whom we have joint marketing agreements

5. It is necessary for our legitimate business purposes, including fraud prevention and monitoring, product and service development and improvement, internal marketing purposes, and operations.

6. In connection with a sale of all or substantially all of the assets of IBF or the merger of IBF into another entity or any consolidation, share exchange, combination, reorganization, or like transaction in which IBF is not the survivor

8. Required or permitted by applicable law, such as to comply with legal requirements and respond to requests from government authorities (including laws and authorities outside your state or country); and.

9. An IP address is a unique identifier that certain electronic devices use to identify and communicate with each other on the Internet. In addition, devices used to access the Internet often carry unique device identifiers, information about browser types, and operating systems. When you visit our Websites, we may collect the IP address, unique device identifier, and other information relating to the device you use to connect to the Internet. We use this information to determine the general physical location of the device and understand from what regions of the world the visitors to the Websites come. We also may use this information to enhance the Websites.

CONSENT

As part of our commitment to keep you informed, we may mail, e-mail, telephone, or contact you by other means to notify you of new IBF products and services, or upcoming IBF special offers, events, enhancements, or other relevant information that may be of interest to you. You may also receive mailings or other communications from carefully selected third parties. We offer you the option to decline any or all of these IBF communications by following the directions included in our e-mails or other communications, or by contacting IBF directly at info@FirelightCamps.com.

We would like to keep all of our guests and visitors informed and equally able to take advantage of the benefits offered by IBF and its strategic marketing partners. However, if you reside outside of the United States, certain data privacy regulations may require us to obtain your permission before we send you information that you have not requested from us.

In some cases, your permission will be implied from the nature of the service requested or transaction undertaken. For example, IBF may collect and use PII that you volunteer, or behavioral data or information collected in the aggregate. In addition, your permission will be deemed given for communications from us that are necessary to fulfill transactions and services that you request.

In certain circumstances, we will seek your express permission when we collect information that is regarded under certain data privacy regulations to be sensitive in nature (e.g., information revealing racial or ethnic origin, political opinions, or health conditions). You may object to IBF disclosing your PII with third parties except when: (i) service providers have been retained to perform services on behalf of IBF; (ii) disclosure is required by law; (iii) disclosure concerns national, legal or public interest grounds; (iv) disclosure is necessary to protect the vital interests of the guest; (v) information has been collected from publicly accessible sources; (vi) disclosure concerns the retrospective processing of the information for historical, statistical or enhancement of guest experiences; or (vii) disclosure is authorized by a supervisory authority (such as a Privacy Commissioner, Data Protection Authority, or other similar authority).

SECURITY SAFEGUARDS

IBF recognizes the importance of information security, and is constantly reviewing and enhancing our technical, physical, and logical security rules and procedures. All IBF owned web sites and servers have security measures in place to help protect your PII against accidental, loss, misuse, unlawful or unauthorized access, disclosure, or alteration while under our control. Although “guaranteed security” does not exist either on or off the Internet, we safeguard your information using appropriate administrative, procedural and technical safeguards. “Phishing” is a scam designed to steal your personal information. If you receive an e-mail that looks like it is from us asking you for your personal information, do not respond. We will never request your Password, User name, credit card information or other personal information through e-mail.

ON-LINE TECHNOLOGIES

IBF and its third party marketing partners may use cookies, invisible pixels, and web beacons to obtain information about you while visiting our web sites. A cookie is a very small text file that is sent to your browser from a web server and stored on your computer’s hard drive. IBF’s cookies assign your computer with a unique identifier, which in turn, becomes your identification card whenever you return to a IBF web site.

Cookies are designed to save you time because they help us to provide you with a customized experience without you having to remind us of your preferences each time you return to our web pages. IBF cookies are not designed to damage your files, nor can they read information from other files on your computer hard drive.

Cookies can also help us provide you with a personalized on-line experience in the following ways:

· they remember your user name and password for future visits so log-in is easier and faster;

· they ensure you are provided with the appropriate frames and content;

· they ensure you obtain all requested information; and,

· they help us deliver communications that are relevant and responsive to your interests and location.

IBF’s cookies are limited to our websites only, and are not designed to follow you when traveling on the Internet after leaving IBF owned websites. We track the usage of our websites in order to better meet your needs and to help make it easier for you to find information in the future. Please note that in addition to IBF cookies, various third parties may also place cookies on your computer’s hard drive. IBF is not responsible for the presence or absence of third party cookies, or for the technological capabilities or practices employed by third parties in connection with third party cookies.

Our services are provided in such a way that the use of cookies is not mandatory. If you would prefer not to have the benefits of cookies, your Internet browser can be adjusted to treat cookies in different ways. Depending upon the type of browser you are using, you may be able to configure your browser so that: (i) you are prompted to accept or reject cookies on an individual basis or (ii) you may be able to prevent your browser from accepting any cookies at all. You should refer to the supplier or manufacturer of your web browser for specific details about cookie security. However, you should also understand that rejecting cookies might affect your ability to perform certain transactions on our web sites and our ability to recognize your browser from one visit to the next.

IBF may also use invisible pixels, sometimes called web beacons, to count how many people visit certain web pages. Information collected from invisible pixels is used and reported in the aggregate and does not contain PII. IBF may use this information to improve marketing programs and content.

We may also work with vendors and marketing partners to help deliver advertisements and personalized content that we believe will be of interest to you. These vendors and other partners include advertisers, advertising agencies, advertising networks, audience segment providers, data exchanges, analytics providers, and other similar providers. These partners and vendors use cookies and web beacons to collect information about your online activity (e.g., the sites and pages you have visited at IBF sites and other third party sites) in order to help IBF (and in some cases, third party advertisers) deliver personalized content and advertising to you while you are on IBF or other sites.In general, you can opt out of our vendors’ use of cookies to tailor personalized content or advertising to you by visiting Network Advertising Initiative and Digital Advertising Alliance Consumer Choice Page.

LINKS TO OTHER WEB SITES

In order to anticipate your needs, IBF provides links to other web sites for your convenience and information. IBF is not responsible or liable for any content presented by or contained on any external independent website, including, but not limited to, any advertising claims or marketing practices. Please note that while IBF will protect your information on IBF owned and operated web sites, we cannot control and will not be responsible for the privacy policies of third party web sites, including web sites owned or controlled by independent franchisees, third party owners of hotel, resort, interval ownership, or residence properties that may use the name of a IBF brand, or web sites not controlled or authorized by IBF. Third party websites that are accessed through links on our web sites have separate privacy and data collection practices, and security measures. Our privacy policy does not apply to any third-party websites, so your interactions with those are governed by the privacy policies of the companies that provide them. We have no responsibility or liability for the practices, policies and security measures implemented by third parties on their websites. We encourage you to contact them to ask questions about their privacy practices, policies and security measures before disclosing any PII. We recommend that you review the privacy statements and policies of linked web sites to understand how those web sites collect, use and store information.

MINORS

IBF does not seek to obtain nor does it wish to receive PII directly from minors; however, we cannot always determine the age of persons who access and use our web sites. If a minor (as defined by applicable law) provides us with his/her data without parental or guardian consent, we encourage the parent or guardian to contact us to have this information removed and to unsubscribe the minor from future IBF marketing communications.

SOCIAL MEDIA PLATFORMS AND WEBSITES

Any information, communications or material of any type or nature that you submit to our Websites (including, but not limited to any IBF website contained on a social media platform or website such as Facebook or Twitter) by email, posting, messaging, uploading, downloading, or otherwise (collectively, a “Submission”), is done at your own risk and without any expectation of privacy.

IBF is not responsible for any content or Submissions contained on such sites and platforms. By visiting any IBF website that is contained on a social media platform or website, you are representing and warranting to IBF that you have reviewed the applicable privacy policy and terms of use of that platform or website and that you will abide by all such provisions contained therein.

Additionally, in the event that IBF offers a message board or any other interactive or social-type feature on a website administered directly by IBF, please be aware that these platforms may allow you to publicly post and share information with other users. Although IBF may take certain precautions to protect those who use these areas of an IBF website, we warn against giving you should not give out any personal data in such public forums as we cannot guarantee the privacy that information will not be private and safety of these areas and may not be monitored and is not guaranteed, and we therefore cannot be responsible for any misused information you choose to post. Your use of these features is fully at your own risk.

HOW TO CONTACT US

If you have any specific questions about this Privacy Policy, you can contact us via email or writing to us at the address below:

info@FirelightCamps.com

406-852-2476

Firelight Camps

1150 Danby Rd.

Ithaca, NY 14850

PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS

Other than stated above in this Privacy Policy, we do not share your personal information with unaffiliated third parties for their own independent marketing purposes. If you are a California resident, you may have the right to request and receive certain information about our disclosure of your personal information to third parties for their direct marketing purposes, and your choices with respect to such disclosures. If you wish to learn more about our compliance with this requirement, please contact us using the information above.